Digital financial asset
A claim — to money, to income or to a stake in a company — that exists as an entry in a dedicated information system rather than as a security held in a custody account.
A digital financial asset is a property right issued and recorded in an information system built on a distributed ledger or another recording technology. The holder of a DFA has a claim against a specific issuer: to receive money on a set date, to receive a share of future revenue, to collect metal from a warehouse, to exercise the rights attached to a stake in a non-public company. In legal terms it is neither a security nor a currency — it is a separate class of object of rights, for which a dedicated record-keeping infrastructure has been created.
How issuance and record-keeping work
The issuer places a DFA not through an exchange and a depository but inside a platform run by an information system operator — an entity listed in the Bank of Russia's register. The platform acts as both the placement venue and the record-keeping institution: the entry in its system is the right itself, and no separate certificate or custody account exists. The technological basis is a distributed ledger, so changing an entry requires coordinated action by the nodes of the system rather than an edit to a single database.
The substance of the right is defined by the issuance decision: the term, the payment procedure, the collateral, the conditions for early redemption. Secondary trading is possible only where it has been provided for — through an exchange operator. Hence the main feature: the liquidity of a DFA depends not on market demand but on whether a resale mechanism has been built for the issue at all.
Access for non-qualified investors
Regulation divides buyers into categories. For an investor without qualified investor status, the annual volume of purchases of DFAs with variable income, that is, income not determined in advance, is capped: RUB 600,000. The cap is calculated on the total amount of acquisitions over a calendar year and works as a risk filter, not as an assessment of the quality of the issue.
Where the term is misunderstood
DFAs are constantly confused with cryptocurrency. These are different objects: a DFA has an obligor against whom the claim is made, whereas a digital currency is an entry with no issuer and no obligation on anyone's part. The second misconception is to treat a DFA as a "bond on the blockchain". Economically an issue may resemble debt, but a DFA is covered neither by the disclosure rules for issuers of securities, nor by exchange listing, nor by the familiar protection provided through a depository. Third: a DFA is not traded on an exchange, so as a rule it has no quote in an exchange order book and no market price — valuation rests on the terms of the issue and the issuer's solvency.